New split sleeper berth provision. What's the formula for 14 hour shift?

But it does say the "two periods." Which leads me to think only one would apply. I'd also think it was the closest.

 

I was in on a conference call to our state DOT and FMCSA with my safety and compliance guy...

Per that conversation...

"In the event that there is more than one qualifying break... The ONE that results in no violation will be used. Multiple qualifying breaks cannot be used and strung together, only one."

@TallJoe in your original post the final example should have been a violation... Even after completing sleeper time, as the longest qualifying break was roughly 3 hours, not the 4 and change needed to extend the 14 out to 23:00.

Looks to me like KT has alot of work to do on thier product. This is a perfect example of why new drivers (not implying TallJoe is a new driver) need to have serious training in HOS, these ELD programmers dont work with HOS day in and day out like we do... The ELD isnt always right.

 

The word "neither" implies 2 breaks... Otherwise it would read "none of the" instead of "neither." This comes down to proper use and understanding of English. Thats not meant as an insult to anyone.

 

Yes that was the conclusion that was reached in the conference call I was part of. For added clarity, IF multiple "shorter" qualifying breaks take place during a single shift then ANY ONE can be used to figure how long to extend the 14 hr clock... But only one. In my opinion it is obvious that the longest "shorter" qualifying break will be the one to use, as it will extend the clock the most....

The only caveat to this is that which ever qualifying break you choose, it must have started BEFORE the NON-extended 14 expired. I say this because it is feasible for a second qualifying break to take place late in the day after already applying the first qualifying break. If one tries to apply this second break, the first break would then count against the 14... And IF, when the first break is counted toward the 14, the 14 expired BEFORE the second break began then obviously a violation occured before beginning a split.... Obviously this is a very edge case, and kind of confusing to wrap your head around. I've actually had to sit down with paper logs and draw out examples for a couple guys to fully explain the concept.

 

I agree 100%... The ELD that my company uses WILL recognise a split... But it will not recalculate your 11 and 14 based on that split, it will just show a violation, with no note that it will be corrected, until both portions of the split are complete. Thus if a driver doesnt understand how the split works one could very easily go into violation unintentionally.

I'm kinda on the fense as to whether or not I like that it wont recalculate it for me... For those of us that understand, it would be nice to not have to figure it out manually. However, for those that dont understand, it may keep them from getting into a situation where they think they should have more time available than they really do and thereby screw up thier schedule.

 

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I interpret the regulation exactly the same as Cattlemen.

While this is perhaps stating the obvious, for solo drivers there is very little likelihood of using the split sleeper provision without having the second half be a full 10 hours. There might be some really odd delivery/pickup combo that the hours make sense, but it would seem to me to be very very unlikely and seldom if ever used the way it is designed (for team trucks that keep rolling). For solo drivers, the split sleeper is merely a way to pause the 14. That's my take on it.

BTW several of the ELDs do not calculate it right, it is not just KT. For all it's faults and dated technology, the QC unit was superior in this respect, imo.

Last I heard the ability to do 4-6 and 5-5 splits is currently under review to add additional flexibility. I have not heard that they decided against it. Others may know more on that.